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Issues: Whether there was material to support the finding that the sum of Rs. 52,500 deposited in the name of the assessee's wife represented the assessee's income from undisclosed sources.
Analysis: The assessee had put forward a specific explanation that the amount belonged to his wife and had been gifted to her by his adoptive father. That explanation was found to be false, as the father-in-law had no available funds and the contemporaneous materials did not support any such gift. The record also showed that the wife had no independent source from which she could have obtained the money. In those circumstances, the rejection of the stated source did not leave the matter at large on a mere presumption; the Tribunal was entitled to draw a conclusion from the proved facts, the comparative means of the persons concerned, and the surrounding circumstances that the money came from the assessee. The earlier decisions relied on by the assessee did not assist him, because the present case turned not on a bare legal presumption arising from title, but on affirmative evidence negativing the only suggested source and on the absence of any other plausible source.
Conclusion: There was sufficient material to support the finding that the amount was the assessee's income from undisclosed sources.